ML17328A165

LER 89-015-00:on 890821,inoperable Open Fire Damper Subj to Constraints of Tech Spec 3.7.10 Found Which Action Statement Requirements Not Implemented.Caused by Misconception by Person Developing Task Sheet for Maint insps.W/890919 Ltr

ML17328A165
Person / Time
Site:	Cook
Issue date:	09/18/1989
From:	Blind A, Droste J INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-015, NUDOCS 8909270245
Download: ML17328A165 (5)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8909270245 DOC.DATE: 89/09/18 NOTARIZED: NO DOCKET FACIL:50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana & 05000316 AUTH. NAME AUTHOR AFFILIATION DROSTE,J.B. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele BLIND,A.A. ,

Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP,NAME RECIPIENT AFFILIATION

SUBJECT:

LER 89-015-00:on 890821, fire dampers inoperable w/o, required compensatory action.

W/8 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR g TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.

ENCL $ SIZE:

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 LA 1 1 PD3-1 PD 1 1 GIITTER,J. 1 1 INTERNAL: ACRS MICHELSON 1 1 ~ ACRS MOELLER 2 2 ACRS WYLIE 1 1 AEOD/DOA 1 1 AEOD/DS P/TPAB 1 1 AEOD/ROAB/DSP 2 2 DEDRO 1 1 NRR/DEST/CEB 8H 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/ICSB 7 1 1 NRR/DEST/MEB 9H 1 1 NRR/DEST/MTB -9H 1 1 NRR/DEST/PSB 8D 1 1 NRR/DEST/RSB 8E 1 1 NRR/DEST/SGB NRR/DLPQ/PEB NRR-~BRBP/~ . B 10 8D 10 1

1 2 2 1

1 NRR/DLPQ/HFB 10 NRR/DOEA/EAB NUDOCS-ABSTRACT ll 1 1

1 1

1 1

EG FILE 02 1 1 'ES/DSIR/EIB 1 .

1 G 3 ILE 01 1 1 EXTERNAL: EG &G WILLIAMS,S 4 4 L ST LOBBY WARD, 1 1 LPDR 1 1 NRC PDR 1 1 NSIC MAYS,G 1 1 NSIC MURPHY,G.A 1 . 1 NUDOCS FULL TXT 1 1 NCTE 'ZO ALL RlIS" RECIPZEÃZS PZEASE HELP US 'ZO REDUCE RASTg.'CZ 'IHE DOCUMEPZ CGNI'K}L DESK RXH Pl-37 (EXT. 20079) KO XKJMZMQR KQR NAMB FKM DISTRISUZICN ZZEGS KR DOCKlMENIS %30 DCH~T NEED!

FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 39 ENCL 39

INDIANA NICHIGiAN POWER September 19, 1989 United States Nuclear Regulatory Commission Document Control Desk Rockville, Maryland 20852 Operating License DPR-74 Docket No. 50-316 Document Control Manager:

In accordance with the criteria established by 10 CFR 50.73 entitled Licensee Event Re ortin S stem, the following report is be>.ng submitted:

89-'015-00 Sincerely, A.A. Blind Plant Manager AAB:clw Attachment cc: D.H. Williams, Jr.

A.B. Davis, Region M.P. Alexich III P.A. Barrett J.E. Borggren R.F. Kroeger NRC Resident Inspector J.G. Giitter, NRC R.C. Callen G. Charnoff, Esp.

Dottie Sherman, ANI Library D. Hahn INPO PNSRC S.J. Brewer/B.P. Lauzau

%90%27() 245 890'P

t '<

pQp +DOCV, 05000326 Intra-System PDi

NRC Form 385 US. NUCLEAR REGULATORY COMMISSION (94)3)

APPROVED DMB NO. 3)500104 LICENSEE EVENT REPORT ILER) EXPIAES: 8/31/88 FACILITY NAME (I) DOCKET NUMSER (2) PA E 3I D. C. Cook Nuclear Plant - Unit 2 050003161OF03

""ire dampers inoperable without required compensatory action as a result, of an erroneous inspection procedure.

EVENT DATE (5) LER NUMBER (6) REPORT DATE 17) OTHER FACILITIES INVOLVED (8)

MONTH DAY YEAR YEAR SEOVENTIAL MONTH DAY YEAR FACILITYNAMES DOCKET NUMBER(S)

NUMBER acS NVMSSR D. C. Cook Unit 1 o 5o o o 315 821 89 89 015.. 0 009 18 8 9 0 5 0 0 0 THIS REPOAT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR (): ICheck One or mOre of the follovflnPI (11)

OPERATING MODE(9) 1 20.402(8) 20.405(cl 50,73(e) (2)(iv) 73.7104)

POWE R 20.405( ~ l(1)(I) 50.38(c)(1) 50,73( ~ )(2)(v) 73.71(cl LEYEL 1 0 P 20.405( ~ lll)(S) 50.38(c)(2) 60.73(e) (2)(cd) OTHER (Specify In Adraect

~' " QN".jf@NA 20.405( ~ l(1)(IB) X 50 73N) 12 l(ll 50.73(e) (2)(vd)) (A) helovr end In Text, IIRC Form 35SAI 20 405( ~ l(1 ) (Ivl 60.73(e)(2)(8) 50.73( ~ )(2)(vld)(B) 20.405( ~ l(1) (vl ,50,73( ~ )12) (III) 50,73(e)(2)(xl LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER AREA CODE J. B. Droste Maintenance Superintendent 6 1 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPOR'T (13)

CAUSE SYSTEM COMPONENT MANVFAC REPORTABLE SYSTEM COMPONENT MANUFAC EPORTABLE (~~a@

TVRER TO NPADS TURER TO NPRDS 'speeaPR>

I)YNmj(~4'AUSE D M P N A N SUPPLEMENTAL REPORT EXPECTED (14) MONTH DAY YEAR EXPECTED SU 8 MlSS 10 N DATE (15)

YES (If yer, complete EXPECTED SVShrISSION DA TEI NO ABSTRACT ILImlr ro te00 rpeced I.e., epproxlmetely flfreen elnpreepece rypevvrirren liner) (ld)

On August 21, 1989 an inoperable open fire damper subject to the constraints of Technical Specification 3.7.10 was found for which the action statement requirements had not been implemented. It had been inspected July 18, 1989, and was identified on a Task Sheet developed for preventive maintenance on dampers which were not subject to the Technical Specification. However; an error was made in identifying non-Technical Specification dampers during development of the Task Sheet and some Technical Specification dampers were incorrectly included. Technical Specification dampers were already included in a Quality Control procedure which contained necessary instructions. The Maintenance inspection overlapped the Quality Control inspection without containing pertinent information needed for Technical Specification dampers.

All Task Sheet Job Orders were reviewed. Two Unit 1 dampers were found which had already been repaired without action statement implementation.

Four more Unit 1 dampers were found with open Job Orders. After ide'ntification of the Technical Specification dampers, the action statement was entered and repairs made. The Task Sheet was revised to delete Technical Specification dampers as originally intended.

NRC Form 3dd (9-83)

NRC Form 366A U.S. NUCLEAR REGULATORY COMMISSION (94)3)

LiCENSEE EVENT REPORT (LER) TEXT CONTINUATION APPAOVEO OMB NO. 3)50M)04 EXPIRES: 5/31/SS FACILITY NAME (II OOCKET NUMBER (3)

LER NUMBER (6) PAGE (3)

BEGUENTIAL rr E v rs ro N YE R Sdo~ NUMBER NUMBER D. C. Cook Nuclear Plant Unit 2-, 0 5 0 0 0 3 l 6 8 9 0 1 5 000 2 OF 0 3 TEXT lllmere 4/rene lr rtqrr/red, rree eddirr(rrre//FRC FOFm 366A'el (17)

CONDITIONS PRiOR TO OCCURANCE Unit One 100 percent thermal power Unit Two - 100 percent thermal power DESCRIPTION OF EVENT On August 21, 1989, with Unit 2 operating at 100 percent reactor power a maintenance mechanic discovered that a fire damper (EIIS/DMP-KQ) he was to repair had not been declared inoperable, nor had a firewatch been established as required by Technical Specification 3.7.10 when the inoperable condition was identified. The Technical Specification also requires that dampers covered by its constraints be repaired within seven days or a special report submitted. The need for repair of fire damper 2-HV-ET-FD-3 in the Unit 2 reactor cable tunnel had been identified July 18, 1989, during an inspection by Maintenance personnel. They were using preventive maintenance Task Sheets which had been developed in March, 1989, with the intent to have Maintenance inspect dampers which were not covered by Technical Specification 3.7.10. Technical Specification dampers have all testing performed by the Quality Control department.

After the discovery, all Job Orders initiated as a result of Maintenance inspections were reviewed to identify any dampers covered by Technical Specification 3.7.10 that had been found to be inoperable. Two Unit 1 dampers were identified that had been repaired August 2, 1989, after being found inoperable on July 17, 1989 and four dampers were identified with Job Orders for repairs also initiated July 17 without the dampers having been declared inoperable and firewatches established. The. Task Sheet utilized for Maintenance inspection of dampers was reviewed and those covered by Technical Specification 3.7.10 were deleted after it was verified the dampers were incorporated in the Quality Control inspection procedure for Technical Specification dampers.

In the case of the four dampers awaiting repair, firewatches were immediately established when the situation was identified and the Unit 1 control room advised of their inoperable status. Maintenance and Construction departments undertook repairs to return all to operable status.

NRC FORM 366A ~ V.S. CPCr )966-SSO-SBB nnn)n 19 S3)

NRC Form 366A U.S. NUCLEAR REGULATORY COMMISSION (9.83 I LICENSEE EVENT REPORT (LER) TEXT CONTINUATION APPROVED OMB NO, 3160-010S EXPIRES: 8/31/88 FACILITY NAME (11 DOCKET NUMBER (2)

LER NUMBER (6) PACE (3)

YEAR SEOVENTIAL . Srt REVISION NUMOER %4) NUMBER

- Unit D. C. Cook Nuclear Plant TEXT /llmoro specs is rtooirtd. ost sdCkitrIS/ /VRC Form 366A's/ ((7) 2 0 5 0 0 0 3 0 l 5 0 0 p OF p

CAUSE OF EVENT The Technical Specification violations resulted from a misconception by the person who developed the Task Sheet for Maintenance inspections., The list for the Task Sheet had been developed from a data base sort of dampers identified as Rnon-safety related." It was incorrectly assumed that dampers which were not "safety related" would not be subject to Technical Specifications. When Job Orders were initiated as a result of the preventive maintenance inspection, dampers were identified as "non-Tech.

Spec." based on information from the Task Sheet.

ANALYSIS OF EVENT This event is considered reportable per the requirements of 10 CRF 50.73 (a) (2) (i) (B) as none of the dampers covered by Technical Specification 3.7.10 were declared inoperable, no firewatches were dispatched, repairs were not made within the seven-day time limit and required Special Reports were not submitted within the 30-day time limit. In each case, all fire loading zones where dampers were located are rated in the low to moderate range. Each zone is also protected by fire detection and/or suppression systems. In the event of fire, these factors combined with the availability of the plant fire brigade, would make it unlikely that a fire would spread beyond its point of origin.

CORRECTIVE ACTIONS All dampers deleted were verified as being covered by an existing Quality Control procedure. The Task Sheet was thoroughly reviewed and revised to delete from Maintenance inspection those dampers covered by Technical Specification 3.7.10.

NRC FORM 366A ~ V.ST CPOs (966-520 ~ SSPr000)0 (043)